Exxon Mobil Corp. v. Healey

Exxon Mobil Corporation (Exxon) filed a petition for writ of certiorari seeking review of the Massachusetts Supreme Judicial Court ruling that permitted Massachusetts Attorney General Maura Healey to proceed with her investigation of Exxon’s marketing and sales of fossil fuel products. Exxon asserted that the case—in which the attorney general made, according to Exxon, “sweeping investigatory requests … for decades’ worth of documents concerning petitioner’s knowledge of, and the relationship of petitioner’s products to, climate change”—involved “a breathtaking assertion of personal jurisdiction over a nonresident defendant.” Exxon argued that the Supreme Judicial Court had applied a “lax” but-for causation standard for determining whether Exxon’s contacts with the state were sufficient to establish specific jurisdiction and that this standard did not comport with due process. Exxon said the case presented “an ideal opportunity” to resolve an open question of the type of relationship that is required between a plaintiff’s claims and a defendant’s forum contacts to satisfy constitutional requirements. Exxon also said the case offered the opportunity “to address a subsidiary question that is vexing the lower courts: specifically whether an unexercised contractual power to be involved in another party’s potential contact with a forum State has any relevance to the specific-jurisdiction inquiry (and, if so, in what way).” Exxon further argued that the Massachusetts high court’s decision was difficult to reconcile with Supreme Court precedent and that the “disarray in the lower courts” provided a basis for Supreme Court review.